ML20137N105

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Response to Applicant Second Set of QA Interrogatories & Requests to Produce Documents.Portions Deleted.Aslb Should Issue Order Protecting Matls from Disclosure.Related Correspondence.Certificate of Svc Encl
ML20137N105
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 01/23/1986
From: Guild R
GUILD, R., ROREM, B.
To:
Atomic Safety and Licensing Board Panel
References
CON-#186-861 NUDOCS 8601290161
Download: ML20137N105 (24)
v • d • e


Text

_ _ _ _ _ _ _ _ - _ . _

"OATED CowEsponogyog January 23, 19,

,f.,\ 1GI l!m,/, A UNITED STATES OF AMERICA 3 NUCLEAR PEGULATORY COMMISSION C i

BEFORE THE ATOMIC SAFETY AND LICENSING BOAPD JgM9,7,', p _.

t' ,

,1

_t In the Matter of:

COMMONWEALTH EDISON COMPANY ) Docket No. 50-456 (Braidwood Nuclear Power

)

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50-457 h b .._ @ '

Station, Units 1 and 2) ) ,

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REPONSE TO APPLICANT COMMONWEALTH EDISON COMPANY'S ,

SECOND SET OF OUALITY ASSURANCE INTERPOGATORIES AND PEOUESTS TO PFODUCE DOCUMENTS DIRECTED TO INTERVENORS BPIDGET LITTLE POPEM, ET AL.

AND MOTION FOR PROTECTIVE ORDER Intervenors Bridget Little Forem, et al., by their under- ,

signed counsel hereby respond to Applicant Commonwealth Edison

. Company's Second Set of Quality Assurance Interrogatories and Pequests to Produce Documents, which were served January 9,1986.

Pursuant to 10 CFR Section 2.740(c), Intervenors move for the entry of a protective order as to each interrogatory and request for production of documents, or portion thereof, to which they herein object. As the Board has previously directed and as the parties have previously undertaken, Intervenors will endeavor to

~

  • / Disclosure of confidential information is strictly limited as provided in the December 6, 1985, Protective Order entered by  ;

the Atomic Safety and Licensing Board in this proceeding. '

Confidential information contained in this document is set of f by brackets [ 1. <

1 G601290161 060123 PDR O

ADOCK 05000456 PDR b

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negotiate and resolve discovery disputes including our objections prior to seeking a ruling f rom the Board on the Motion For Protective Order.

By way of introduction Intervenors note that thirteen of the fourteen interrogatories posed in this "second se t" are identical to those interrogatories served August 16, 1985, and identified as " Applicant Commonwealth Edison Company's First Set of Quality Assurance Interrogatories and Requests To Produce Documents Directed to Intervenors Bridget Little Forem, Et A 1. " As Appli-cant no doubt expects, Intervenors' responses here are, thus,

, virtually the same as those provided in our August 16, 1985, Fesponse and Motion for Protective Order regarding Applicant's first set of interrogatories.

As we understand from Applicant's counsel the principal purpose of the second set of interrogatories is to seek updated inforamtion with respect to the identities of persons raising Quality Control inspector harassment and intimidation claims.

Intervenors t.ad objected to disclosing names or other iden-tifying information regarding certain Comstock OC inspectors who sought confidential treatment of such information it. this proceeding. Pesponse, August 16, 1985, pp. 6, 11-21. The Licensing Board subsequently entered a Protective Order December 6, 1985, providing for the limited disclosure of such confidential information. Intervenors here disclose confidential information sought by Applicant's interrogatories as provided for in the Board's Protective Order. ,

1 Applicant seeks the production of documents from Intervenors '

l 2

for inspection and copying. Documents identified in the answers to the following interrogatories, except those which are privileged, will be made available for inspection and copying at counsel's office in Chicago, Illinois, at a time to be agreed upon. In the course of preparing for the litigation of this contention, advising and communicating with intervenors and others, documents are prepared by counsel or at counsel's direction which are privileged and not subject to discovery pursuant to 10 CFR Section 2.74 0(b)(1). Such documents as trial preparation materials are subject to a work product privilege and

, an attorney-client privilege protects from disclosure the mental impressions and opinions of counsel. 10 CFR 5 2.74 0 ( b) (:2 ) . Such documents as handwritten notes, m<smoranda and other documents prepared by Intervenors' counsel or at counsel's direction are privileged and protected from disclosure. Intervenors object to the production of such documents and ask the Board to enter an order protecting such materials from disclosure.

01: Describe every oral communication which you have had which refers or relates to each subpart of the contention by:

a. dater
b. whether the communication was on the telephone or in person;
c. the subject matter of the communication; and

. d. identify all persons participating therein.

You may exclude all such communications in which counsel for Staff and/or Applicant participated.

3

A1: This interrogatory impermissibly seeks the description of "every" oral communication "which refers to relates to" the subparts of the contention participated in by Intervenors' " attorneys, including all employees of BPI."

Intervenors object to the description of communications which are exempt from discovery as attorney-client and attorney work pro-duct privileged information. Oral communication by and among Intervenors' counsel, counsel's employees, agents and advisors, Intervenors, and persons seeking legal advice are protected from discovery. 10 CFR S2.740(b)(1) and (b)(2); Pule 26(b)(4),

Federal Pules of Civil Procedure. To the extent Applicant seeks communications by " Stanley Campbell and Diane Chavez" as included in the definition of the terms, "you and your," Intervenors object .n relevance grounds since neither Mr. Campbell nor Ms.

Chavez are parties to this proceeding and no communication between them and counsel is relevant to the Ouality Assurance issues. Aside from oral communication in which counsel (or counsel's employees and agents) were participants, no other communication is believed to have occurred as sought by this interrogatory.

Counsel for Intervenors have had oral communications with a number of prospective expert consultants and advisors, none of whom are presently expected to be called as witnesses at trial.

Intervenors object to. disclosing the identities of these persons or the content of the communication (s) with them. 10 CFR S 2.740(b)(2 ); Pule 26(b)(4), Federal Pules of Civil Procedure.

Intervenors' counsel have had oral communications with a 4

number of present and former Braidwood site employees. In light of the serious claims involving harassment and intimidation of such site employees, Intervenors are concerned that simply disclosing the existence of such communications with counsel for Intervenors may subject such persons to reprisal or fear of reprisal which, at the least, may have a chilling effect on their willingness to cooperate with Intervenors and participa'te in this proceeding. The names of confidential prospective witnesses are disclosed below pursuant to the terms of the Board's December 6 Protective Order. Such confidential information is set out in brackets and is to be disclosed only as provided in the Protective Order. Intervenors object to describing such oral communications with counsel since such communications are not discoverable. Applicant can interview such persons itself to obtain the same information.

The following oral communications are identified in which counsel for Intervenors participated:

1. July 9-14, August 31, October 18, November 3, 1985 John D. Seeders
2. July 9-10, October 18, 1985 Worley O. Puckett
3. July 9, 1985 Lee Hornberger
4. July 15, 1985 Frank Martorana
5. July 24, 30, 1985 L.G. McGregor
6. July 14, 29, 1985 Dan Holley
7. July 29, 1985 Pichard Snyder
8. July 30, 1985 Tim Stewart
9. July 31, 1985 Herschel Stout 5
10. August 1, 1985 P.D. Hunter
11. August 1, October 18, 1985 1
12. July 31, 1985 j
13. August 1, November 18, 198 January 5, 1986
14. July 31, 1985
15. August 2, 1985
16. July 30, November 18, 1985
17. August 2, 1985 [
18. August 1, 1985 W
19. August 1, 1985 July 31, 1985

, 20.

6 On May 17 and 24, 1985, counsel had oral communications with an unknown person who had knowledge of facts relevant to the amended OA contention. Intervenors object to describing such I communication since a description may serve to identify this person who clearly desired and sought anonymity. The nature of the communication persuades Intervenors that the person has a legitimate interest in remaining anonymous.

02: Identify the documents in your possession prior to

~

the admission of the contention which refer or relate to each subpart of the contention and identify each person supplying you wit.h each document.

A2: The pleadings and exhibits previously served upon Applicant and filed in this proceeding refer or relate to the contention. The documents identified as exhibits to these plead-ings were supplied by the NRC Staf f in the case of inspection f

6

reports, by the Court Reporter in the case of.the Keppler-Wernick Deposition and the Keppler Byron testimony, the Chicago Tribune in the case of the article quoting Mr. Keppler, and by Applicant in the case of the several Commonwealth Edison documents. Other documents consist of attorney work product and attorney-client privileged materials the identification and production of which is objected to. In addition, counsel for Intervenors received documents believed to be from the anonymous individual referred to in Interrogatory 1, above. Intervenors decline to describe or produce such documents since they would likely provide identi-fying information which would compromise this individual's anony-mity.

03: Identify each individual and organization with

" quality assurance expertise" whom you have consulted concerning Braidwood and identify each document which refers to relates to such consultation.

A3: Intervenors object to disclosing the identities of or substantive communication from the persons with OA expertise referred to, where none of these persons are, at present, expected to be called as witnesses at trial. 10 CFR S 2.74 0 (b) (2 );

Rule 26(b)(4), Federal Rules of Civil Procedure.

04: Define the word " breakdown" as it is used in the contention.

A4: Intervenors employ the word " breakdown" as a term of art with the same meaning as is attached to the word by the NRC as, for example, in 10 CFR Section 50.55('e) and in the Atomic 7

Safety and Licensing Appeal Board decision in the Callaway case, ALAB 74 0,18 NRC 3 43 (19 83).

05: For each subpart of the contention describe the corrective action which has been or is being implemented to correct the deficiency described therein.

A5: Intervenors answered this guestion with respect to corrective action regarding each deficiency cited in each subpart-of the contention in our August 1, 1985, Response to the NRC Staff's July 12, 1985 Interrcgatories. We reiterate such answers at this time. Such answers were provided in response to Interrogatories 3, 4, 8, 9, 12, 13, 16, 17, 22, 23, 26, 27, 30, 31, 34, 35, 38, 39, 42, 43, 46, 47, 50, 51.

Further descriptions of asserted corrective actions are contained in Applicant's August 27, 1985, Sixth Partial Response to Intervenors' first set of interrogatories, answers to specific interrogatories 58 and 59; and in Applicant's November 15, 1985 First Partial; November 22, 1985 Second Partial; December 6, 1985 Third Partial; and December 12, 1985 Fourth Partial Responses to Intervenors' second set of interrogatories. A final report on Applicant's Material Traceability Verification Program was transmitted November 15, 1985. A first report on Applicant's Braidwood Construction Assessment Program was transmitted November 18, 1985. A final report on the Corroded Pipe Problem was transmitted January 10, 1986. A written program description and partial results of the Safety-Related Mechanical Equipment Retrofit Program were transmitted January 13, 1986.

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06: For each corrective action identified in answer to Interrogatory 5, state whether you believe the corrective action has been or will be, if implemented in accordance with its description, effective in rectifying the specified quality assurance deficiency. If your answer is negative, describe fully the particulars in which the corrective action is asserted to be ineffective, the basis for each such assertion and identify all documents which refer or relate to your answer.

A6: Intervenors answered this guestion with respect to corrective action regarding each deficiency cited in each subpart of the contention in our August 1, 1985, Fesponse to the NRC Staff's July 12, 1985 Interrogatories. We reiterate such answers at this time. Such answers were provided in response to Interrogatories 3, 4, 8, 9, 12, 13, 16, 17, 22, 23, 26, 27, 30, 31, 34, 35, 38, 39, 42, 43, 46, 47, 50, 51.

Intervenors are unable at this time to form an opinion on the effectiveness of these asserted corrective actions prior to their completion, their review by the NFC and the completion of discovery regarding such actions.

07: State whether you will contend at the hearing that the specific factual occurrences set forth in the contention exhibit an asserted pattern of quality assurance deficiencies on any common basis other than the specified criterion of 10 CFP Part 50, App. E set forth in the contention. If so, describe each such common basis for an asserted pattern of ouality assurance deficiencies and identify any documents which refer or 9

relate to such common basis.

A7: This interrogatory appears to seek the disclosure of the legal opinions or theories of Intervenors' counsel and, as such, it is objectionable as addressed to privileged attorney work product. It also prematurely would require Intervenors to take a position on such legal theories before we have had an adeauate opportunity in discovery to ascertain evidence of common bases and patterns. Fven at this stage, however, evidence of such patterns and common bases have been identified, for example, by NBC Pegional Administrator James G. Keppler who observed that such serious deficiencies were a product of Applicant's manage-ment being " spread thin at the top." February 1, 1984, Chicago Tribune, "Will County A-Plant Faulted - ' Worse' Than Byron."

Further, in his May 7, 1984, letter to Applicant Mr. Feppler stated that "[A] major factor contributing to the deficiencies were inadequate contractor programs and workmanship, inadequate licensee reviews of the contractor programs, and inadeguate licensee quality assurance overview to ensure contractor activities met all requirements."

08: Define the words harassment, in tim id a tion, retal-f ation and discrimination as used in the Joint Stipulation on Quality Control ("0C") Inspector Harasscent Contention (" Joint Stipulation").

A8: The terms harassment, intimidation, retaliation and discrimination as used in the contention, collectively represent policies, practices, acts or omissions by Commonwealth Fdison or its contractors intended to or having the effect of 10 h

impeding, interfering with, or improperly influencing the performance of quality assurance duties by Braidwood site employees. Such conduct includes discrimination as defined and prohibited under the Employee Protection provisions of the Energy Peorganization Act, 42 USC Section 5851 and 10 CFP Section 50.7, and pressure to sacrifice quality and safety interests out of cost and schedule considerations.

09: Describe each instance of (A) harassment and (B) intimidation either (1) carried out or (2) participated in by Irv DeWald, Larry Seese, Bob Seltman and F.M. Sakalac and for each such instance:

a. identify the OC inspector or other Comstock employee allegedly harassed or intimidated;
b. identify the Comstock supervisor involved;
c. describe the quality or safety concern expressed by the OC inspector or other Comstock employee;
d. state whether the quality or safety concern was resolved and if so, describe its resolution;
e. state the date of each such instance; and
f. identify documents which refer or relate to each such instance.

A9: 1. a. John D. Seeders

b. Sakalac, Seltman, Seese, DeWald
c. complained about harassment in connection 11

with his QC duties as described in his August 17, 1984 letter and his November 4 and 5, 1985 deposition

d. not resolved
e. in August 1984, subsequently involuntarily transferred out of OC
f. August 17, 1984 letter
2. a. Worley O. Puckett
b. Marino, DeWald
c. improper construction procedures, improper qualification of welders, material traceability deficiencies; recommended complete stop work order for all welding activity, as further described in his December 6, 1985 deposition
d. not resolved 1
e. May-August 1984
f. see, documents attached to July 12, 1985, Motion To Admit Claims of Intimidation and Harassment of Comstock Quality Control (OC) Inspectors and identified in his December 6, 1985 deposition
3. a. Pick Snyder
b. Sakalac
c. refused to close out inspection document with open engineering change notice
d. March 28, 1985 12
e. not resolved
f. April 5, 1985 NBC Memo
4. a. ]
b. John Walters, Ken Worthington
c. told he'd be discriminated against if he did not produce more inspections; work with blinders on
d. unknown
e. unresolved
f. April 5, 1985 NRC Memo
5. a. R.D. Hunter
b. more than one supervisor
c. more than a little bit of intimidation
d. unknown
e. not resolved  !
f. April 5, 1985 NBC Memo
6. a.
b. Sakalac, other Comstock management 1
c. told to finish an inspection even though drafting errors noted
d. not resolved l

l e. November 5, 1984 l

l

f. April 5,1985 NRC Memo
7. a.
b. John Walters, Daryl Landers
c. observed base metal reduction; Walters 1

told him not to worry; Landers said to 13 l

I i

keep production up

d. unknown e, unknown
f. April 5, 1985 NRC Memo
8. a. Herschel Stout
b. unknown
c. produc tion overrides quality
d. not resolved
e. unknown
f. April 5, 1985 NRC Memo
9. a.
b. unknown
c. quantity first, not quality
d. not resolved
e. unknown
f. April 5, 1985 NRC Memo
10. a.
b. Sakalac, DeWald
c. Sakalac berates inspectors; DeWald has discriminated against many inspectors; attitude is "how can I hang you"
d. not resolved
e. unknown
f. April 5, 1985 NRC Memo
11. a.
b. Sakalac
c. Sakalac lied to get him fired; Sakalac 14

used forms contrary to procedure; constantly being watched; involuntarily transferred after visiting NRC office

d. not resolved
e. unknown
f. April 5, 1985 NRC Memo
12. a.

m

b. unknown
c. hangers not inspected, just as-built; no inspection report on nonconformances writ-ten; walkdowns done, drawings made to show as-built configuration
d. not resolved
e. unknown
f. April 5, 1985 NRC Memo
13. a.

M

b. unknown
c. more money for more certifications; can't remain proficient in all areas; quality goes down
d. not resolved
e. unknown
f. April 5, 1985 NRC Memo l
14. a. Dan Holley b unknown l

l 15 l l

l

c. Sam Russman both QC inspector and auditor

- conflict of interest

d. unknown
e. unknown
f. April 5, 1985 NBC Memo
15. a. Inspector "X" (believed tobejlllll
b. Sakalac
c. told X to close out ICR's without going through engineering; Sakalac threatened him; "I can put you in the vault;"

Inspector X says that everyone knows about Sakalac, but nothing is ever done.

Tells me what to do though not certified; isn't qualified; just done to get the paper work complete

d. not resolved
e. unknown
f. March 29, 1985 NBC Memo
16. a. "another individual"
b. Sakalac
c. knows of at least 5 guys Sakalac has jumped on; nothing gets done; telling inspectors what to do when he's not certified in area; railroaded John out; new leads in who can't answer questions in their areas but will sign of f NCR's or 16

ICR's without appropriate disposition; told to keep numbers of NCR's and ICR's down; interested in numbers and not quality; wrote up guy who didn't have enough numbers; Ouality First program sucks, hasn't done a damn bit of good; threw me out of inspecting cable pans -

too many NCR's; engineers signed off - no problem. Out of 100 bangers last week all but one or two no good. Supervisor wanted me to close out several ICR's - not certified in my area. Sakalac pressured me to close them out; going to weed out inspectors based on production, not quality.

d. not resolved
e. unknown
f. March 29, 1985 NRC Memo
17. a. " individual"
b. Sakalac
c. new people just closing out documents without inspections; afraid of Sakalac; no training; complained to CECO about "use as is" disposition of NCR's to avoid re-work; one person completed 93 hangers with 1,114 welds in one day; improper QA auditing
d. not resolved 17
e. unknown 1
f. March 29, 1985 NRC Memo
18. a. Inspector A
b. unknown
c. new hires will complete paperwork; "get i

the job done" j d. not resolved i e. unknown l f. March 2'), 1985 NRC Memo

19. a. Inspector B 4
b. unknown '
c. in 15 years of inspecting, first nuclear job where quantity first, not quality
d. not resolved
e. unknown
f. March 29, 1985 NRC Memo
20. a. Inspector C
b. Sakalac

. c. gave up lead position because of

+

l intimidation; Sakalac uses extreme i

profanity; attitude is how can I hang you j not help you i

d. not resolved
e. unknown
f. March 29, 1985 NRC Memo
21. a. Inspector D 9
b. Sakalac

! 18

c. no overtime unless production increased; Sakalac threatened inspector to sign off ICR
d. not resolved
e. unknown
f. March 29, 1985 NRC Memo
22. a. Inspector E
b. unknown
c. intimidation far worse than one supervisor or lead
d. not resolved
e. unknown
f. March 29, 1985 NRC Memo
23. a. Inspector F
b. Sakalac
c. many run-ins with Sakalac; demanded he write up electrician or lose qualification
d. not resolved
e. unknown
f. March 29, 1985 NRC Memo
24. a. Inspector G
b. unknown
c. being watched; they are keeping book so they can fire me
d. not resolved
e. unknown
f. March 29, 1985 NRC Memo l l

19 l l

l

25. a. all inspectors present
b. unknown
c. quantity first, quality work or inspections were secondary
d. not resolved
e. unknown
f. March 29, 1985 NBC Memo j Q10: Describe each effect of Mr. Sakalac's alleged I

harassment which remains uncorrected, identify each person on j whom each such ef fect has operated and identify all documenta

, which refer or relate to each effect.

A10: The effect of the widespread harassment miscon-duct by Mr. Sakalac is to undermine the integrity of all of the j inspection work performed by those who worked under his super-vision or subject to his influence. All inspection documents i executed by such persons are suspect.

011: Identify each r,f the "more than 25" Comstock QC

inspectors referred to at page 4 of the Joint Stipulation dated

! July 12, 1985.

All: The identities of the more than 25 Comstock OC inspectors who complained to the NFC since at least August 1984,

are not specifically known to intervenors. We are informed of i

such a fact but not of the names' of each of the inspectors.

4 According to the NRC, 24 inspectors complained of harassment on March 29, 1985. See, April 5, 1985, NPC Memo at page 2.

012: Identify each of the Comstock OC inspectors 20

referred to at pages 13-21 of "Pesponse to Applicant Commonwealth Edison Company's First Set of Quality Assurance Interrogatories and Requests to Produce Documents Directed to Intervenors Bridget Little Borem, et al. and Motion for Protective Order:

dated August 16, 1985.

i A12: The following Comstock OC inspectors referred to in our August 16 Pesponse, pp. 13-21, are identified:

4a. Inspector "I":

6a.

W Inspector "II":

i

)

7a. Inspector "III":

9a. Inspector "IV":

10a. Inspector "V":

lla. Inspector "VI": )

12a. Inspector "VII":

ummmusumur 13a. Inspector "VIII": >

i 15a. Inspecto "X I" : " Inspector X" believed to be 013: Identify each and every person who you intend to call as a witness at the hearing in this matter on the contention, and with respect to each such person:

a. Describe the witness' education and professional background;
b. State the substance of the facts and opinions to 21 J

which the witness is expected to testify;

c. Give a summary of the ground for each opinion; and i
d. Identify all documents which form the basis for

! each opinion.

! A13: Intervenors have not at present identified any 1

l persons intended to be called as witnesses in the proceeding except as previously noted in our July 12, 1985, Motion To Admit Claims of Intimidation and Harassment of Comstock Ouality control l

(OC) Inspectors. However, pursuant to 10 CFR S 2.74 0 (e)

Intervenors intend to seasonably supplement this response as required.

014: State the full name, address, occupation and employer of each person answering the interrogatories or i assisting in the preparation of such answers, and designate the

interrogatory or the part thereof he or she answered.

A14: These interrogatories are being answered by the undersigned counsel for Intervenors. No consultants or other advisors are relied upon for such answers.

DATED: January 23, 1986

, Respectfully submitted, I \

Robett Guild ()

One of the AttTrneys for I

Robert Guild Intervenor Rorem, et al .

Douglass W. Cassel, Jr.

, Timothy W. Wright, III 109 North Dearborn I Suite 1300

! Chicago, Illinois 60602 1 (312) 641-5570

, 22

. o 1/23/86 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of: )

)

COMMONWEALTH EDISON COMPANY ) Docket No. 50-456

) 50-457 (Braidwood Nuclear Power )

Station, Units 1 and 2) )

, CERTIFICATE OF SERVICE I hereby certify that I have served copies of Response to Applicant Commonwealth Edison Company's Second Set of Quality Assurance Interrogatories and Fequests to Produce Documents Directed to Intervenors Bridget Little Forem, et al. and Motion For Protective Order on each party to this proceeding as shown on the attached Service List, by having said copies placed in envelopes, properly addressed and postaged (first class), and deposited in the U.S. mail on this 23th day of January, 1986.

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- - - - , - - - - . . , - , , - - - . - , , - , - , - , , - . - - . . - - . - . -rw,,,,.,----n --. - - - - - . , , . - ~ , . - -

r BRAIDWOOD SERVICE LIST

  • Herbert Grossman, Esq.
  • Michael I. Miller, Esq.

Chairman and Administrative Judge Peter Thornton, Esq.

Atomic Safety and Licensing Board Isham, Lincoln & Beale U.S. Nuclear Regulatory Commission Three First National Plaza Washington D.C. 20555 Chicago, Illinois 60602

  • Richard F. Cole Docketing & Service Section

, Administrative Judge Office of the Secretary Atomic Safety and Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington D.C. 20555 Washington D.C. 20555

  • A. Dixon Callihan C. Allen Bock, Esq.

Administrative Judge P.O. Box 342 102 Oak Lane Urbana, Illinois 61801 Oak Ridge, Tennessee 37830 Bridget Little Rorem

  • Stuart Treby, Esq. 117 North Linden Street NRC Staff Counsel Essex, Illinois 60935 U.S. Nuclear Regulatory Commission i 7335 Old Georgetown Road Thomas J. Gordon, Esq.

l Bethesda, Maryland 20014 Waller, Evans & Gordon 2503 South Neil

!

  • Joseph Gallo, Esq. Champaign, Illinois 61820 Isham, Lincoln & Beale 1120. Connecticut Avenue N.W. Lorraine Creek Suite 840 Route 1, Box 182 Washington D.C. 20036 Manteno, Illinois 60950 Region III office of Inspection &

i Enforcement l U.S. Nuclear Regulatory l Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington D.C. 20555 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory i Commission l Washington D.C. 20555 l , .. l

  • Received version containing confidential information.

l l

l c ]

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